The Petitioner, a naturopathic physician running a private practice in rural Minnesota, sought to continue treating cancer and other patients using integrative/naturopathic medicine, and volunteered to write exam items for the naturopathic physicians' licensing board.

Prong 1 — national importancenot established · dispositive

“the Director concluded that the Petitioner's "services appear to only impact a population in Minnesota"”

“the record does not establish that her clinical work would impact the naturopathic field and healthcare industry more broadly, as opposed to being limited to the patients she serves”

“In determining national importance, the relevant question is not the importance of the industry or profession in which the individual will work”

“The record, however, does not demonstrate that her medical practice has significant potential to employ U.S. workers or otherwise offers substantial positive economic effects for our nation”

“the evidence does not demonstrate that the implications of her proposed volunteer service for NPLEX and the potential prospective impact of this work rise to the level of national importance”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “letters of support from patients explaining how the Petitioner provided them with quality medical care”

  AAO decision text
• other · discounted

  “the record does not establish that her clinical work would impact the naturopathic field and healthcare industry more broadly”

  AAO decision text
• degree · credited
• motion resubmission · discounted

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Local, not national scope · p1 — impact confined to clients / a region

Notable

AAO expressly rejected an 'impact of the industry' argument, distinguishing the field's importance from the specific endeavor's importance; also addressed volunteer exam-writing work as a separate potential endeavor and found it insufficient both in scope of time devoted and in national importance.

Authorities this decision leans on

From the doctrinal survivor set — 187 authority tests across 47 distinct authorities cleared the differential-lift gates. Only those appear here.

• INA 203(b)(2)

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